Pragmatic Environmentalist of New York

On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  According to a New York State Department of Environmental Conservation (DEC) bulletin dated May 10, 2021, the Advisory Panels to the Climate Action Council have all submitted recommendations for consideration in the Scoping Plan to achieve greenhouse gas (GHG) emissions reductions economy-wide.   My posts describing and commenting on the strategies are all available here. This post addresses one aspect of the Energy Efficiency & Housing Advisory Panel enabling strategy recommendations, namely heat pump propaganda.

I have written extensively on implementation of the CLCPA closely because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   I briefly summarized the schedule and implementation CLCPA Summary Implementation Requirements.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations,  summarized some of the meetings and complained that its advocates constantly confuse weather and climate in other articles.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

In my post on the Energy Efficiency & Housing Advisory Panel scoping plan recommendations to the Climate Action Council I noted that in their presentation the first mitigation strategy is an initiative to modify building codes and standards as shown in the following slide.  The plan is to amend the state codes for new construction, including additions and alterations, to require solar PV on “feasible” areas, grid-interactive electrical appliances, energy storage readiness, electric readiness for all appliance and electric vehicle readiness.  They propose to adopt these all-electric state codes for single family residences by 2025 and for multifamily and commercial buildings by 2030. The presentation notes that by 2030, more than 200,000 homes per year will be upgraded to be all-electric and meet enhanced energy efficient standards.

I think garnering support for this initiative is a major challenge for proponents.  New York homeowners have extensive experience dealing with winter weather and heating their homes.  Selling the changeover to an electric heating system will be a heavy lift particularly for anyone who has lived through a multi-day wintertime electric outage.   

The panel recognizes this and included education as a possible mitigant many times throughout their recommendations.  For example, one of the components required for delivery for Energy Efficiency & Housing Advisory Panel Enabling Initiative #4: Public Awareness and Consumer Education is to:

Support and scale up multilingual public and consumer education efforts through a large-scale, coordinated awareness, inspiration and education campaign; traditional and broad reaching media, digital communication, “influencer” style campaigns, user-generated campaigns, out of home displays, magazines, mailers, virtual tours; resources for installers, distributors, home-visiting workforce, other supply chain actors to educate consumers, customer-facing resources and tools.

When I read this I cringed because there are so many instances when the climate-related proclamations from the state are not just a little wrong they are off-scale wrong and can only be call propaganda. Propaganda is defined as material disseminated by the advocates of a doctrine or cause.  There are many propaganda techniques including “card stacking”.  This technique is a feature of the CLCPA:

It involves the deliberate omission of certain facts to fool the target audience. The term card stacking originates from gambling and occurs when players try to stack decks in their favor. A similar ideology is used by companies to make their products appear better than they actually are.

In this post I will present an email I recently received from the New York State Energy Research & Development Authority describing the use of heat pumps for home heating and cooling in the following section.  I will then discuss aspects of the email that make heat pumps appear better than they actually are.

Even when the CLCPA was still a proposal it was obvious that electric heating would be necessary to meet the greenhouse gas emission reduction targets proposed.  I wrote a post titled Air Source Heat Pumps In New York over two years ago that explains how heat pumps work and describing a research study that showed the problems with heat pumps in cold climates that make them worse than the NYSEDA description.  I will summarize the technology and the fundamental problem here but if you are interested in more details, I refer you to my previous post.

According to the Department of Energy heat pumps are very efficient because they move heat rather than converting it from a fuel like combustion heating systems do.  Air source heat pumps move energy from the air and ground source heat pumps move energy from underground water.  Note that because ground source heat pumps require digging, air source heat pumps are the preferred retrofit technology.  Unfortunately, there is a big problem with air source heat pump systems and improperly designed ground source heat pumps.  In particular when the weather gets really cold there is insufficient energy in the air or underground water to provide adequate heat when it is transferred. 

Myth Buster: The Heat Pump Edition

The following is the text from a NYSERDA email titled “Myth Buster: The Heat Pump Edition”.  It also is available in a web link.

With the beautiful days of summer upon us, there’s no better time to reevaluate your home’s current heating and cooling options than right now.

If your current system is reaching its end-of-life or if you’re just looking for ways to save energy and money while keeping your home as comfortable as possible this summer, you may want to consider a heat pump as an alternative heating and cooling option. Heat pumps provide even, clean, and energy-efficient heating and cooling throughout your home, without the random hot and cold spots that other types of heating systems are known for.

You’ve probably heard a few things around heat pumps and the New York State climate that may have you scratching your head, but we’re here to help dispel four of the most common myths around heat pumps to help put your mind at ease.

Myth #1: Heat pumps don’t work in cold climates. 

This is one of the most common myths we hear about heat pumps – that they’re only effective in warm environments. The truth is, today’s heat pumps are equipped with the most up-to-date technology that allows them to produce efficient, superior heating in temperatures as low as -13 degrees Fahrenheit. Even in subzero temps, high quality heat pump units can heat up quickly and provide even, comfortable heating without cold spots throughout your home and without the need for supplemental heat.

Myth #2: Heat pumps create heat. 

Heat pumps don’t actually create heat — they simply move it from one place to another. Even during the winter, there is some degree of heat that still exists in the air or the ground. Heat pumps remove this heat and transfer it into your home.

Myth #3: Heat pumps are useless during the summer months.

Although they are called “heat pumps,” these systems are actually two-in-one, capable of heating and cooling. During the summer, heat is drawn out of the home, and, through the use of a reversing valve, which essentially flips the flow of coolant through the system, allows air to be cooled before re-entering the home. 

Myth #4: There is only one kind of heat pump.

When it comes to heat pumps, you actually have two primary options – a ground source heat pump or an air source heat pump. Also known as a geothermal heat pump, ground source heat pumps draw air from the ground and transfer it evenly into your home, and reverse the process during the summer. Air source heat pumps extract heat from the air outside and distribute it evenly into your home. As with geothermal heat pumps, the process is reversed during warmer months.

Discussion

I will address the propaganda in the components of the NYSERDA email below.

In the introduction, NYSERDA claims “Heat pumps provide even, clean, and energy-efficient heating and cooling throughout your home, without the random hot and cold spots that other types of heating systems are known for.”  A moment’s thought raises the question: how can the type of heating system affect hot and cold spots?  In order to make a heat pump viable, the structure has to be very well insulated and any air infiltration reduced as much as possible.  That kind of structure will reduce the number of random hot and cold spots.  As I understand it, the retrofit approach is to replace a fossil-fired furnace with a heat pump replacement.   Any random hot and cold spots from issues with the existing duct system won’t be addressed by a heat pump per se.  To address those issues the heating system ductwork would have to be replaced.  Moreover, in order to make the heat pump viable the insulation and infiltration issues need to be addressed.

The first myth addressed is “Heat pumps don’t work in cold climates”.  The American Council for an Energy-Efficient Economy published a paper that illustrates the cold climate region problem with air source heat pumps:  Field Assessment of Cold Climate Air Source Heat Pumps (ccASHP).  The report describes a Center for Energy and Environment field study in Minnesota where cold climate air source heat pumps were directly compared to propane and heating oil furnaces.  The report notes that “During periods of very cold temperatures when ccASHPs do not have adequate capacity to meet heating load, a furnace or electric resistant heat can be used as backup.”  The NYSERDA document does not mention the need for a backup system and, frankly, it is not clear how retaining a fossil-fired backup system will be allowed by the CLCPA.  As a result, the backup system will be highly inefficient radiant electric heat.

Figure 2 from the document graphically shows the problem.  In this field study homes were instrumented to measure the heat pump and furnace backup usage.  Backup furnace usage was relatively low and the heat pump provided most of the heat until about 20 deg. F.  For anything lower, heat pump use went down and the furnace backup went up.  Below zero the air source heat pumps did not provide any heat and furnace backup provided all the heat.  NYSERDA claims “The truth is, today’s heat pumps are equipped with the most up-to-date technology that allows them to produce efficient, superior heating in temperatures as low as -13 degrees Fahrenheit”.  Obviously when the temperature is lower than -13 aka when you want heat the most, an air source heat pump is worthless.

The second myth is “Heat pumps create heat”.  I have no issue with the response itself but the comment “Even during the winter, there is some degree of heat that still exists in the air or the ground” does not address the flaw described earlier.  In particular, there always is some heat in the air but the question is when does the amount of heat become so low that extracting usable heat is not viable.

The third myth is “Heat pumps are useless during the summer months”.  This is a great advantage to this technology because they can be used in reverse in the summer to provide air conditioning.  In more southerly locations this makes the technology a good choice as long as there is backup heating capability for the rare cold snap. 

The last myth is “There is only one kind of heat pump”.  I have no issue with this response.

Conclusion

To sum up my discussion, I believe that there are two problems with the plan to deploy air source heat pumps.  While air source heat pumps might work most of the time the fact is that when the need for heat is greatest in New York, they won’t provide sufficient heat so a backup system is needed. I believe radiant electric heat will be the preferred option for air source heat pump conversions. When the CLCPA mandate for all electric heating is implemented along with electric vehicles I am sure that local electric distribution systems will have to be upgraded at considerable expense.  Ultimately the problem is that these worst-case conditions for heat correspond to the worst annual wind and solar resource availability.  Where is the energy for this heating boondoggle going to come from? 

In several different proceedings I have voiced my concerns about air source heat pump technology in Upstate New York when temperatures are below zero.  In those comments I referenced the results from Field Assessment of Cold Climate Air Source Heat Pumps.  I recommended that NYSERDA do a similar analysis using the newer technology that allegedly eliminates the issues raised in the study.  The response has been crickets.  Until such time that there is a follow up study that supports NYSERDA’s claims and refutes the results of this study, I don’t believe any heat pump propaganda from NYSERDA.

There is another aspect to the plan to electrify home heating.  I don’t think the system is going to work well during typical cold snaps and I have serious doubts about the worst-case polar vortex outbreaks.  Unfortunately, the very worst case is an electric outage in the winter.  I survived a multi-day electric outage in the winter using a gasoline powered generator to provide power to my natural gas furnace.  The Department of Energy heat pump description noted that heat pumps move heat because they move heat rather than converting it from a fuel like combustion heating systems do.  That overlooks the ability of combustion heating systems to store fuel for use when needed.  That is a critical resource for electric outages that proponents of heat pumps ignore.

At the end of the day, I think there will be tremendous pushback when the all-electric heating requirements are rolled out.  For me personally, the requirement for an all-electric home is a deal breaker for remaining a resident of the state.  I don’t think I am the only one.

On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  According to a New York State Department of Environmental Conservation (DEC) bulletin dated May 10, 2021, the Advisory Panels to the Climate Action Council have all submitted recommendations for consideration in the Scoping Plan to achieve greenhouse gas (GHG) emissions reductions economy-wide.   My posts describing and commenting on the strategies are all available here. This post addresses the Land Use and Local Government Advisory Panel Adaptation and Resilience Recommendations presented at the June 8, 2021 Climate Action Council meeting.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   I briefly summarized the schedule and implementation: CLCPA Summary Implementation Requirements.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations,  summarized some of the meetings and complained that its advocates constantly confuse weather and climate in other articles.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

Buried in the CLCPA are two amendments to § 9. Chapter 355 of the laws of 2014, constituting the community risk         and resiliency act that add two new sections 17-a and 17-b.  The amendments read as follows:

• 17-a. The department of environmental conservation shall take actions to promote adaptation and resilience, including:

(a) actions to help state agencies and other entities assess the reasonably foreseeable risks of climate change on any proposed projects, taking into account issues such as: sea level rise, tropical and extra-tropical cyclones, storm surges, flooding, wind, changes in average and peak temperatures, changes in average and peak precipitation, public health impacts, and impacts on species and other natural resources.

b) identifying the most significant climate-related risks, taking into account the probability of occurrence, the magnitude of the potential harm, and the uncertainty of the risk.

(c) measures that could mitigate significant climate-related risks, as well as a cost-benefit analysis and implementation of such measures.

• 17-b. Major permits for the regulatory programs of subdivision three of section 70-0107 of the environmental conservation law shall require applicants to demonstrate that future physical climate risk has been considered. In reviewing such information, the department may require the applicant to mitigate significant risks to public infrastructure and/or services, private property not owned by the applicant, adverse impacts on disadvantaged communities, and/or natural resources in the vicinity of the project.

One of the tenets of pragmatic meteorologists is that extreme weather is going to happen with or without climate change.  Therefore, adaptation and resilience measures for known extreme weather risks is an obvious “no-regrets” approach to mitigate weather-related impacts.  This post will discuss the approach proposed and the solutions suggested for adaptation and resilience. 

Adaptation and Resilience Recommendations

The Land Use and Local Government Advisory Panel outlined the perceived problem, described 12 adaptation and resilience recommendations in three categories, and claimed a number of benefits and impacts in the presentation to the Climate Action Council (recording here).  

One of the ironies of the presentation was that there were repeated appeals to the “science” even as the discussion ignored the scientific process.  Central to the scientific method is the idea of empirical falsification whereby theories are scrutinized and tested using data and facts.  Importantly, this means evaluation of all the data.  Albert Einstein once said, “No amount of experimentation can ever prove me right; a single experiment can prove me wrong.”  The CLCPA process routinely picks and chooses its supporting science arguments but ignores any conflicting evidence.

In order to justify the adaptation and resilience recommendations there was a slide listing “New York’s climate vulnerabilities”.  The CLCPA rationale for the transition away from fossil fuels is that climate change is a reality and our future is at stake.   I recently summarized recent articles debunking the “climate emergency” meme.  I have also set up a page that provides links to posts on the claims that the effects are being seen now and there is a climate emergency that dictates action now.  I also have a page with posts highlighting the  difference between weather and climate which is constantly mistaken by Climate Leadership and Community Protection Act (CLCPA) advocates.  Based on that work, I believe the slide is mostly cherry-picked baloney.

The justification for action veers even further from the science in the slide “Significant risk in continuing GHG emissions”.  The claim that there could be 100s of billions of dollars of damages per year is only possible “under a high emissions scenario”.  That scenario has been described as “increasingly implausible with every passing year”.  Roger Pielke, Jr. explains “Evidence indicates the scenarios of the future to 2100 that are at the focus of much of climate research have already diverged from the real world and thus offer a poor basis for projecting policy-relevant variables like economic growth and carbon dioxide emissions.”  Nonetheless, the CLCPA advisory panels and state agencies trot out this propaganda at every opportunity.  The fact is that they pick and choose the quotes that support their claims for inevitable climate catastrophe and ignore all contradictory findings.  That is not “science”.

The panel proposed 12 enabling strategies in three categories.  Under “Building Capacity” they proposed four enabling strategies: AR1: Commit to creating, implementing and updating a comprehensive and equitable state climate change adaptation and resilience plan; AR2: Incorporate equitable adaptation and risk-reduction considerations into relevant state funding and regulatory programs, projects and policies; AR3: Strengthen meaningful community engagement and public education, and build adaptive capacity across all sectors; and AR4: Identify and evaluate options for supporting equitable adaptation and resilience practices and projects, and to enhance insurance protection.  The “Communities and Infrastructure” theme had five strategies: AR5: Provide state agency planning and technical support for equitable regional and local adaptation and resilience plans and projects; AR6: Evaluate opportunities to ensure equitable consideration of future climate conditions in land-use planning and environmental reviews; AR7: Develop policies, programs, and decision support tools to reduce risks associated with coastal and inland flooding; AR8: Develop policies and programs to reduce human risks associated with new patterns of thermal extremes; and AR9: Ensure the reliability, resilience and safety of a decarbonized energy system.  The last category, “Living Systems” had three enabling strategies: AR10: Develop policies and programs to reduce risks threatening ecosystems and biodiversity; AR11: Enhance climate resilience and adaptive capacity of agricultural community, while preparing to take advantage of emerging opportunities; and AR12: Develop policies and programs to preserve and protect the ability of forest ecosystems to sequester carbon.  I am not going to address each of these strategies but will highlight some issues with some of them.

“Building capacity” refers to yet another plan with its associated bureaucracy, including adaptation and risk-reduction considerations into relevant state funding and regulatory programs, projects and policies; identification and evaluation of options for supporting equitable adaptation and resilience practices and projects. Finally, there is the indoctrination recommendation to “strengthen meaningful community engagement and public education” no doubt continuing the theme of carefully selected “science” as the rationale for all this planning.

I agree with the concept of a state adaptation and resilience plan but I believe that it would be more appropriate to emphasize observed extreme weather rather than alleged climate impacts.  Most of the people involved in the CLCPA implementation don’t understand, don’t want to understand, or understand but have vested interests to ignore the fact that we don’t understand the climate system well enough to project how much of an effect, if any, reductions in GHG emissions will have on observed weather.  The fact is that society does not have a resilient plan for extreme weather so even though the rationale is wrong, the concept of a plan to address extreme weather is a good one. 

The proposal includes an update the New York State Energy Research & Development Authority’s (NYSERDA) ClimAID report.  The last edition squandered a lot of money for climate scientists to run models and claim that they could distinguish the climate signal in New York.  Naturally all the results were consistent with New York’s climate agenda.  I expect nothing different this time.  Unfortunately, the enabling strategies continually refer to using the projections from this analysis in their planning processes.  If the analyses use the inappropriate emissions projections described above, the result will over-estimate potential effects and unnecessary resources will be expended for unlikely projections.

The theme of “communities and infrastructure” is to develop a planning process that incorporates consideration of future climate conditions. Specific strategies for coastal and inland flooding as well as “new patterns of thermal extremes” are proposed.  The benefit of implementation is: ”reduction of climate risks results in direct health and safety benefits”.  This includes the biggest oversight in the presentation.

The final enabling strategy for communities and infrastructure is “Ensure the reliability, resilience and safety of a decarbonized energy system.”  The Climate and Community Investment Act’s Legislative findings and declaration stated that Superstorm Sandy “caused at least 53 deaths and $32 billion in damage in New York state”.  In February 2021, severe winter weather in Texas caused at least 151 deaths, property damage of $18 billion, economic damages of $86 billion to $129 billion, and $50 billion for electricity over normal prices during the storm.   For years prior to the storm about $66 billion was spent on wind and solar in Texas.   In addition, the wind and solar sectors collected about $21.7 billion in local, state, and federal subsidies and incentives.  The problem in Texas is that when electricity is needed most, weather conditions are least conducive to wind and solar production.  New York is embarking on the same approach, has the same renewable resource availability problem, and should expect the same sort of impacts if a winter storm knocks out the electric system when heating and transportation are electrified.  This enabling strategy is critical but not because of climate impacts.  It is much more likely that the transition to renewable energy to meet the CLCPA targets will be the problem that affects reliability, resilience and safety.

The theme “living systems” had three enabling strategies: policies and programs to reduce risks threatening ecosystems and biodiversity, “enhance climate resilience and adaptive capacity of agricultural community” and policies and programs to preserve and protect the ability of forest ecosystems to sequester carbon.  These enabling strategies suffer from the same oversight as the previously discussed reliability, resilience and safety strategy.  The greatest threat to New York’s living system is the land needed to build all the wind and solar facilities needed to produce enough renewable energy to replace fossil fuels.  An analysis done for NYSERDA on wind power and biodiversity found that: “5,430 square kilometers (1.3 million acres) of land in New York that are both suitable for wind power development and avoid areas that are likely to have high biodiversity value. Using an estimate of 3.0 MW/square kilometers, this translates to a megawatt capacity estimate of 16,300 MW (± 9,000 MW) for New York’s terrestrial landscape.”  The latest projections suggests that twice as much wind power development will be required which obviously means that development will occur in areas of high biodiversity value.  Surely the space needed for wind and solar development will also adversely affect agriculture lands and forests.  Also unrecognized is the fact that in rural areas where electric outages are common residents commonly use wood stoves for backup.  When the requirement for all electric homes kicks in, I think the demand for wood for heating will soar which will adversely affect the ability of forest ecosystems to sequester carbon.

Benefits and impacts

The presentation to the Climate Action Council had three slides describing benefits and impacts.  The first argued that because disadvantaged communities are most vulnerable to climate change it presents an opportunity for the CLCPA implementation to address those vulnerabilities.  While I have no issue with the concept that disadvantaged communities should be targeted, I worry that the potential for all the programs to increase energy costs will mean that many of those least able to afford higher energy prices will not get the support they need to prevent energy poverty.  The disconnect between inevitable higher energy prices with very little direct benefits to those least able to afford those increases and the support for programs that cause higher energy prices by environmental justice organizations befuddles me.  Ultimately poorer people will have a more difficult time adapting and becoming more resilient to extreme weather and the alleged effects of climate change.  I will address this issue when I post on the recommendations from the Climate Justice Working Group. 

Health benefits are commonly ascribed to actions that consider climate change.  The presentation’s slide lists direct health benefits.  Someone, somewhere following the climate change funding bandwagon has undoubtedly made claims for those benefits.  I leave it the reader to consider how likely these alleged benefits could be linked to climate change as opposed to other factors

Another common theme for CLCPA proponents is that implementing these programs will create jobs.  During this process no one has raised the possibility that higher energy prices might force businesses to re-locate or go out of business so job losses are a real potential.    There is one other aspect of this slide that needs to be highlighted.  There is a graphic image that includes a quotation that states that UCLA professor Christa Tirado said in 2011 “in 2020, the UN has projected that we will have 50 million climate refugees”.  It is 2021, and rather than relying on a ten-year old projection I believe it would be more appropriate to document where the climate refugees are.  Absent that verification I can only label this as another example of cherry-picked propaganda.

Conclusion

In my 45-year air pollution meteorology career there has been more than one instance where I got the right answer but for the wrong reason.  For example, while evaluating air quality models that predict the impacts of power plants, I found that the models were protective of human health and welfare because they conservatively predicted downwind concentrations compared to observations.  However, there were instances when the models predicted the highest concentrations for one set of meteorological conditions and the observed highest concentrations occurred during a different set of conditions.  Right answer for the wrong reason.

In my opinion this sums up the CLCPA adaptation and resilience recommendations.  I agree that this is something that should be done because our current infrastructure is not resilient to observed extreme weather.  However, the rationale for these recommendations is that they need to be done because of climate change impacts.  Proponents of the CLCPA believe that any unusual weather is due to climate change caused by human emissions of greenhouse gases.  That opinion flies in the face of the “science” that the naïve believe supports their position and common sense.  Given that climate has always been changing and that historical CO2 levels have varied more than current observations, common sense says that whatever effect anthropogenic greenhouse gas emissions have on weather is a tweak and not the primary driver of observed weather variations. 

Finally, I showed that the greatest threat to the reliability, resilience, and safety of the electric system is not climate change but the proposed plan to rely on intermittent and diffuse wind and solar resources to provide most of the electric energy in the state.  Furthermore, the greatest threat to ecosystem biodiversity is the land use that will have to be converted to utility-scale wind and solar facilities.  There simply is not enough land suitable for wind development that does not have high biodiversity value to prevent development where it will have significant impacts.

On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  This post highlights some of the aspects of the enabling strategies needed to meet the targets that I believe the general public does not know is headed their way.

I have written extensively on implementation of the CLCPA closely because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

According to a New York State Department of Environmental Conservation (DEC) bulletin dated May 10, 2021, the Advisory Panels to the Climate Action Council have all submitted recommendations for consideration for the Scoping Plan that will be used to achieve the necessary greenhouse gas (GHG) emissions reductions economy-wide.  Advisory panels were created to develop recommendations for the Scoping Plan and made presentations at the April 12, 2021 Meeting and the May 10, 2021 Meeting and recordings of the presentations are available.  I provide links to all those recommendations and my posts describing them here.  The following summarizes what has been suggested.

In the past month or so the same politicians who managed to foist the CLCPA upon the citizens of New York advocated for the Climate and Community Investment Act (CCIA) which was intended to provide funding to support the CLCPA implementation efforts.  I wrote several posts on the legislation and talked to my local assemblyman’s office about my concerns.  In that conversation a WHAM report that the carbon tax alone would bring in $2.3 billion a year and could increase gasoline costs 55 cents a gallon was mentioned as the main reason the assemblyman was not supporting the legislation.

The costs for the enabling strategies are not known but it will be expensive so this is going to prove very unpopular based on the response to the CCIA.  The Transportation Advisory Panel proposed a strategy to transition to 100% zero-emission light duty vehicle sales which I believe mandate that all light-duty vehicles sold starting in 2035 have to be electric.   The panel claims that by 2028 electric vehicles (EVs) will be comparable in cost to an internal combustion engine.  Of course, all the infrastructure to support EVs in public ($1 billion to the utilities so far) will have to be covered, homeowners who purchase the vehicles will have to purchase at home charging support, and when every home has an EV the local electrical distribution systems will have to be upgraded as I discussed in my comments on the transportation panel strategies.

The energy efficiency and housing advisory panel sector emissions were the highest of any sector.  As a result, the primary mitigation strategy is to phase out fossil fuel use in buildings.  A primary enabling strategy is to change codes and standards as shown in the following slide.  The plan is to amend the state codes for new construction, including additions and alterations, to require a plethora of specific requirements including solar PV on “feasible” areas, grid-interactive electrical appliances, energy storage readiness, electric readiness for all appliance and electric vehicle readiness.  They propose to adopt these all-electric state codes for single family residences by 2025.  Note that a homeowner that chooses to an addition or alteration could be covered by the same requirements.    In 2030, gas/oil replacements will be prohibited when heating and hot water systems have to be replaced in homes and in 2035 electric stoves and driers are mandated replacements.  I expect that there is a requirement that when a house is sold after 2030 that it will have to be all-electric.  If you prefer to use natural gas for home heating, hot water, and cooking you will not have that choice.

The presentation notes that “Resilience is of critical importance”. There is a major disconnect between the advisory panel and the public in this regard.  For the public, a slogan does not keep the house warm.  In the event of extreme weather such as an ice storm many people had experience surviving because of fossil fuel options.  I doubt the public will willingly give up the resilient capabilities of natural gas and fuel oil for heating.  I described these issues in more detail in this post.

The Land Use & Local Government Advisory Panel proposed a theme facilitating “responsible siting and adoption of clean energy sources” apparently oblivious to the fact that clean energy siting requires much more land than available at any of the priority development areas simply because wind and solar energy are diffuse and require large areas to collect it.  The Agriculture and Forestry Advisory Panel proposed enabling strategies to avoid forest conversion and avoid agricultural land conversion because of the role of forests and farmlands in sequestering carbon. There is no recognition or plan to address the extraordinary buildout of wind generation projected by the Analysis Group – 35,200 MW compared to 5,905 MW in the last state impact statement that evaluated wind energy cumulative impacts.  Note that there are less than 2,000 MW of wind turbines today.  Responsible siting, minimizing conversion of sequestration land, and reducing cumulative impacts of thousands of turbines while developing the thousands of wind turbines is a significant challenge.

The waste advisory panel recommendations illustrate one overarching problem with these panels.  In light of the critical need for firm, zero-emissions resources and the fact that the methane emissions from municipal solid waste landfills, digesters at water resource recovery facilities, livestock farms, food production facilities and organic waste management operations are a major percentage of the total emissions, it only seems logical to address both problems by collecting and using that gas.  However, as I showed in my analysis of the waste strategies, there are passionate ideologues involved that don’t agree.  The meeting minutes note “concern regarding renewable natural gas, suggesting that there is a limited opportunity for it to contribute to Climate Act goals and believes that efforts in this area benefit the source without contributing additional environmental benefits”. Another member “expressed his concerns about how to move ahead with biogas if it is combusted as this would clearly increase net co-pollutants locally, and suggested the Council consider applications for biogas that would not be combusted (such as fuel cell technology at wastewater treatment plants)”.  

The Energy-Intensive and Trade-Exposed Industries Advisory Panel illustrates a less-than flattering aspect of the CLCPA.  The strategies for the small and declining industrial, mining, and manufacturing sector were described as “heterogeneous”.  This means that there are many different sources so economy of scale is not going to reduce costs.  Clearly New York’s unilateral transition off fossil fuels will increase relative energy costs relative to other jurisdictions and industries will have to leave to survive.  They conclude that this sector needs currently unavailable solutions to produce emission reductions and remain viable within the state.  It seems pretty obvious that this advisory panel was included as a political ploy to placate the industrial sector.  Unfortunately, there is not much that can be done to reduce emissions significantly or prevent the remaining industries from fleeing the state out of necessity.

The Power Generation advisory panel is arguably the most important because in order to meet the targets all the other sectors will have to be electrified. The recommendations are available in a slide presentation.  I did a review of final recommendations, and, because this panel is most closely related to my background and interest, I posted earlier on the draft recommendations.  At the start of the process, I also posted on the membership of this panel.  The Albany politicians who nominated the members of the panel chose people whose ideological agendas are aligned with the CLCPA presumption that the transition away from fossil fuels is simply a matter of political will.  As a result, they included enabling strategies for the process of, for example, developing off-shore wind, but the related strategy did not include costs for actually developing offshore wind facilities or offer enabling strategies for it.

The ultimate problem replacing fossil fuels with renewable wind and solar energy is providing power during periods when both renewable resources are near zero.  In their presentation to the Power Generation Advisory Panel on September 16, 2020, E3 included the following slide that notes that illustrates the winter doldrum issue.  Incredibly, the panel recommendations did not specifically address this issue. 

Conclusion

This post highlights some of the aspects of the enabling strategies needed to meet the CLCPA emission reduction targets that I believe the general public does not know are headed their way.  Given the constant harping from politicians and the media about the existential threat of climate change many might believe implementing this law is appropriate.  However, the question is just how much is the public willing to pay and how many limitations on personal choice will they accept?

All these recommendations will be incorporated into the integration analysis modeling effort by the State.  Technical staff at the agencies will develop the scoping plan that outlines what is needed to meet the law’s requirements and maintain reliability.  The scoping plan goes to the Climate Action Council for review and comment and the public even gets a chance to respond.  Once the scoping plan is accepted State agencies will implement codes and regulations.  The proponents of the CLCPA are convinced that they have broad public support for these changes in personal choice and the inevitable higher prices.

This year’s CCIA legislation was intended to cover CLCPA implementation costs and the thought that the carbon tax alone would bring in $2.3 billion a year and could increase gasoline costs 55 cents a gallon apparently was too much to bear.  Those costs are a fraction of the CLCPA costs.  The proposed enabling strategy for residential home heating mandates that all new homes built after 2025 be all-electric and that when fossil appliances have to be replaced after 2030 that they be replaced by electric alternatives that the public will have to cover.  All new light-duty vehicles sold in 2035 will be electric.  In order to transition the electric grid Kevin Kilty points out “It took money spent over a century to learn the systems engineering currently built into the grid. It will take a lot of money to duplicate all this for a completely re-imagined grid in a decade.”  New Yorkers need to wake up and ask for the costs of this legislation sooner rather than later.

On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  According to a New York State Department of Environmental Conservation (DEC) bulletin dated May 10, 2021, the Advisory Panels to the Climate Action Council have all submitted recommendations for consideration in the Scoping Plan to achieve greenhouse gas (GHG) emissions reductions economy-wide.   My posts describing and commenting on the strategies are all available here. This post addresses the Power Generation Advisory Panel enabling strategy recommendations, including my impressions of the panel presentation itself.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   I briefly summarized the schedule and implementation: CLCPA Summary Implementation Requirements.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations,  summarized some of the meetings and complained that its advocates constantly confuse weather and climate in other articles.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Power Generation Emissions

Although the presentations all follow the same format the details differ.  One of the more important components of the presentations is the emissions estimates and they all include a graphic showing historical emissions in 1990, “preliminary draft” emissions for 2018, and their projections for 2030 and 2050.  A constant theme with this panel compared to others is a lack of critical information for stakeholders trying to understand their recommendations.  The ultimate reason for the recommendations is for emission reductions and this presentation does not provide all the numbers whereas most of the presentations included the values for each year.

The 1990 emissions were defined in the Department of Environmental Conservation’s Part 496 regulations but the sectors used in that regulation are not comparable to this advisory panel’s sector.  In the following graph I estimate that the 1990 emissions are 100 million metric tons (MMt) of carbon dioxide equivalent[1] (CO₂e) and 2018 preliminary draft emissions are 60 MMt. 

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[1] The amount of carbon dioxide by mass that would produce the same global warming impact as the given mass of another greenhouse gas over a specific time frame, as determined by the IPCC, and as provided in Section 496.5 of this Part.

There are two emission reduction targets in the CLCPA: 40% reduction in GHG emissions by 2030 and 85% reduction in GHG emissions by 2050.   The slide provides the percentage reductions so that the emissions can be estimated.  The projected total reductions emission reduction goals for this advisory panel are a 71% reduction from 1990 by 2030 and a reduction of 95% by 2050.  However, the power generation sector has its own goals: 70% renewable energy by 2030 and 100% carbon-free electricity by 2040.  No documentation is provided to substantiate the claim that 70% renewable energy is equivalent a 50% reduction from the 2018 levels.

The power generation sector was the third largest source of greenhouse gas (GHG) emissions in 2018.  Direct combustion emissions accounted for 57% of the total, imported fossil fuel 28%, oil and gas methane leakage 15%.  The inclusion of emissions by imported fossil fuels and leakage is mandated by law, ECL § 75-0101(13). These two categories represent an estimate of what may be referred to as the lifecycle, fuel cycle, or out-of-state upstream emissions associated with in-state energy demand and consumption.  However, these sectors are not included in internationally accepted emission inventory procedures.  I am working on a post that addresses this issue specifically.

 Power Generation Strategies

According to the meeting presentation, the advisory panel proposed fourteen enabling strategies:

1             Growth of Large-Scale Renewable Energy Generation

2             Clean Energy Siting & Community Acceptance

3             Distributed Generation / Distributed Energy Resources

4             Existing Storage Technology

5             Demand Side

6             Reliability for the future grid

7             Access and Affordability for All

8             Workforce Development

9             Market Solutions

10           Technology Solutions

11           Long Duration Storage Technology

12           Energy Delivery & Hosting Capacity

13           Gas Infrastructure, Transmission & Methane Leakage

14           Retirement of Fossil Fuel-Fired Facilities

The recommendations are available in a slide presentation.  I am not going to critique each of these strategies individually because it would take far too long.  Instead, I will comment on a few things with an emphasis on inconsistencies and implementation issues.  Because this panel is most closely related to my background and interest, I posted earlier on the draft recommendations.  I will also compare the proposed strategies to the draft strategies.

In September 2020 I also posted on the membership of this panel.  That post describes how this process was supposed to work.  I also described the background of the panel members.  I noted the members were mostly aligned with the ideological agenda of the Cuomo Administration rather than maintaining an affordable and reliable power generation system.  Sadly, the events of the last six months or so exceeded my expectations.  In order to make power generation recommendations it is necessary to understand how the power system works and how planning affects reliability and affordability.  Many of the members did not want to understand and did not try to understand the technological challenges.  Unfortunately, they were the loudest voices and their naïve insistence on speculative technologies has resulted in some risky enabling initiatives.

Discussion

One of the good things that this presentation did include were the category definitions.  Each mitigation strategy describes the potential effect of the strategy on GHG reductions by 2030, cost and funding expectations, and ease of implementation in three categories: low, medium and high.  The following tables define what they mean by low, medium and high.  This panel and the Energy Efficiency & Housing panel were the only ones to include these definitions and I note that there are subtle differences between them.  For example, the Power Generation panel defines the low mitigation strategy cost as <$250M total resource cost and most resources required for successful implementation are already on hand.  The other panel uses the same definitions but expresses the value as “equivalent annualized cost”.

I appreciate the inclusion of these definitions.  However, I don’t think some of the category definitions for the enabling initiatives are correct.  In particular, Initiative #1, Growth of Large-Scale Renewable Energy Generation states that the cost and funding considerations are $, <$250 million total resource cost for NYSERDA’s existing Tier 1, Tier 4, and offshore wind programs.  The only way those estimates can be correct is if they are referring only to the process for growing large-scale renewable generation.

The New York State Energy Research & Development Authority (NYSERDA) offshore wind website notes that the State’s five currently planned offshore wind projects total 4,300 MW.   The US Energy Information Administration (EIA) regularly assesses the levelized costs of all power sources, and only a year ago calculated that the cost of offshore wind was $115.04/MWh.  EIA claims a capacity factor of 45% which means that the 4,300 MW will generate 16,950,600 MWh.  Using the EIA levelized cost of electricity, see below, with that amount of generation yields $1.9 billion for the 4,300 MW of offshore wind.  Something else to keep in mind is that this projection does not include costs on the wholesale market, capacity market, or impacts on balancing and ancillary service markets which all add to the cost.  The biggest concern is providing power when the wind is not blowing.  It is hard to imagine how the authors of this slide managed to estimate that these costs would be less than $250 million unless they were only talking the process.  Then the question becomes where the heck do these costs show up in the recommendations.

Reliability

In general, the greatest threat to grid reliability is the transition away from fossil-fired power plants that provide dispatchable electricity whenever needed to intermittent and diffuse generation from wind and solar.  Donn Dears book “The Looming Energy Crisis” provides a detailed description of potential problems associated with this transition.  In this post I am only going to address two CLCPA aspects.

The final recommendations to the Climate Action Council at least emphasized the need to maintain reliability.  Incredibly, the first presentation from the Climate Action Council on the advisory panels did not mention reliability.  There are extensive electric system reliability requirements in place and despite numerous requests, no presentation on New York’s requirements was provided to this panel. 

Moreover, enabling initiative #6, reliability for the future grid, misses the point.  As shown in the following description the cost and ease of implementation refer to the process for maintaining reliability, not the difficulty of making the changes needed to make the system reliable.  For example, in August 2019 there was a blackout in England.  Initially triggered by a lightning strike followed by “Two almost simultaneous unexpected power losses” from an offshore wind farm and a gas-fired power plant resulted in a “cumulative level of power loss greater than the level required to be secured by the Security Standards” and the blackout ensued.  My point is that as the system transitions to renewables I expect this kind of trial and error de-bugging of the system reliant on intermittent renewable energy.  For example, the North Park Solar proposal calls for a facility with up to 450 MW of solar panels covering 2500 acres.  What happens on a partly cloudy day when the incident solar radiation varies wildly?  Could that trigger an unexpected power loss? 

A reliable electric power system is very complex and must operate within narrow parameters while balancing loads and resources and supporting synchronism. New York’s conventional rotating machinery such as oil, nuclear, and gas plants as well as hydro generation provide a lot of synchronous support to the system. This includes reactive power (vars), inertia, regulation of the system frequency and the capability to ramping up and down as the load varies. Wind and solar resources are asynchronous and cannot provide these necessary grid ancillary support services.  Earlier this year I wrote that no one seemed to want to take the responsibility to figure out was is needed to provide that support. 

Enabling initiative #9, Market solutions, is the only place in the recommendations where ancillary services is mentioned.  Similar to the problem for the reliability initiative, this recommendation discusses the market mechanisms rather than the problem itself.  The responsibility for the initiative is on the New York Independent System Operator (NYISO).  The barriers to success note that this “Will require several forward-looking market designs and the implementation of each design must be structured in a way that sends the correct price signal at the appropriate time”.  This panel unloads all the responsibilities onto the NYISO. Not only do they have to anticipate all the potential issues in an unprecedented system reliant on asynchronous generation but also have to create a market mechanism to get market participants to invest in that technology.  This is another trial-and-error exercise where the rate-payers of the state are lab rats.

Feasibility

I have always maintained that the fundamental flaw of the CLCPA is that it assumed it was only a matter of political will to completely transform the existing electrical system to one dependent upon renewable energy.  Clearly, it would be appropriate to define affordability and reliability metrics then do a comprehensive analysis to determine if the transition would threaten those metrics.  The following tables list the ease of implementation descriptions for all 14 enabling strategies.

There are three easy to implement strategies: Reliability for the future grid, Workforce Development, and Gas Infrastructure, Transmission & Methane Leakage. These strategies are supposed to have been implemented many times and/or can build off an existing NYS program, rely on Proven and widely available technology, and the key stakeholders are strong supporters, there were no strong opponents.  However, recall that the reliability strategy was more about the mechanics of assessing reliability than actually addressing the problem.  It is ludicrous for this panel to claim reliability for a wind and solar dependent electric generation system will be “easy”.

Most of the strategies had a medium ease of implementation defined as: strategy is new to New York State but has been successfully implemented in other comparable states/countries, proven technology with known GHG impact, but still small-scale, and key stakeholders are neutral, or balanced mix of supporters and opponents.  I think the biases of the panel members and their lack of technical backgrounds impact these ease of implementation estimates.  Consider the medium label for existing storage technology.  Despite all the fawning reports over Tesla’s utility-scale batteries, the press and this panel has not picked up on how they are being used.  The Australian Hornsdale Power Reserve battery system is making money for the operators and saving consumers money by providing frequency control ancillary support services.  It is not being used to provide meaningful energy storage for the system.  As a result I argue that claiming that utility-scale energy storage has been successfully implemented is dubious at best.

There are three initiatives that even this panel had to conclude would be hard to implement: long duration storage technology, energy delivery & hosting capacity, and retirement of fossil fuel-fired facilities.  I believe that both existing and long duration energy storage technologies should be difficult.  A recent article by Kevin Kilty “Why is Energy so Difficult to Store? Why is Stored Energy so Difficult to Use?” described the generic problems with energy storage systems. He concluded that “It took money spent over a century to learn the systems engineering currently built into the grid. It will take a lot of money to duplicate all this for a completely re-imagined grid in a decade.”  Long-duration storage is necessary so depending upon a technology that does not even exist in a pilot project is an incredible risk.

Energy delivery & hosting capacity refers to “planning and implementation processes to facilitate necessary energy delivery options for the renewable energy buildout”.  Like all the other strategies by this panel it is presumed that there are no technical challenges to accomplish this.  In fact, this reads like a wish list for the renewable energy developers on the panel. 

Retirement of fossil fuel-fired facilities engendered a non-consensus recommendation with majority support: “temporary moratorium on new or repowered fossil fuel-fired facilities until the full recommendation is adopted”.  The strategy description is to develop a plan and implement regulations to phase out fossil fuel-fired baseload and peaking generation resources as quickly as practicable while retaining system reliability by prioritizing efforts to lower emissions of co-pollutants in disadvantaged and environmental justice communities.   The current cause célèbre amongst environmental justice activists are power plants in disadvantaged communities because they just have to be causing health problems due to ozone and inhalable particulates.  The problem is that those are both secondary pollutants and form long after the precursor pollutants are emitted so any health effects are not due to neighborhood power plants.  The mitigating solution to this non-problem: “The recommendations from the Power Generation Advisory Panel focus on enabling strategies to assist in the transition away from fossil fuels. These include strategies to more rapidly deploy renewable technologies, including flexible resources, addressing barriers to renewables deployment, transmission and distribution upgrades, developing and deploying technology innovations, encouraging effective market structures, and ensuring a just and equitable transition.”  As near as I can interpret this, there is absolutely no inkling that there might be technological and physical barriers that could preclude any of these enabling strategies.

Affordability

The panel covers affordability with its own enabling initiative.  I find it rich that the panel presumes that Federal Relief Funds should be used first.  The problem is that similar efforts elsewhere have markedly increased costs.  According to Germany’s Enegiewende program, the share of renewables in electricity generation should reach 45 percent by 2030 and 100% by half century.  The costs have sky rocketed and now German electricity prices are three times higher than France.  The Global Warming Policy Foundation has analyzed the cost of Great Britain’s net-zero programs concluding that astronomical cost burden risks are becoming a “toxic issue” for the government. If CLCPA proponents could point to a single jurisdiction with high renewable energy use that did not experience a marked increase in costs, then I would not believe this is an insurmountable problem.

Conclusion

Two things about this advisory panel.  It is arguably the most import panel because achieving CLCPA will only be possible if zero-emission electric power is available.  It was inarguably the worst run panel by far.  John Rhodes “leadership“ was abysmal and by the time he retired the damage had been done.  A leader would have steered discussions to achievable solutions that could maintain current levels of reliability and affordability.  What happened is that the loudest voices in the room drove the recommendations and discussions. As David Zaruk, who writes at the Risk Monger blog, explains those voices are: “millennial militants preaching purpose from the policy pulpit, listening to a closed group of activists and virtue signaling sustainability ideologues in narrowly restricted consultation channels”.  Rather than trying to understand the technological challenges these idealogues made recommendations for processes that would enable what they believe only requires political will.  “It is hard to imagine a more stupid or more dangerous way of making decisions than by putting those decisions in the hands of people who pay no price for being wrong.”– Thomas Sowell

On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  According to a New York State Department of Environmental Conservation (DEC) bulletin dated May 10, 2021, the Advisory Panels to the Climate Action Council have all submitted recommendations for consideration in the Scoping Plan to achieve greenhouse gas (GHG) emissions reductions economy-wide.   My posts describing and commenting on the strategies are all available here. This post addresses the Energy Efficiency & Housing Advisory Panel enabling strategy recommendations.

I have written extensively on implementation of the CLCPA closely because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   I briefly summarized the schedule and implementation CLCPA Summary Implementation Requirements.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations,  summarized some of the meetings and complained that its advocates constantly confuse weather and climate in other articles.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Energy Efficiency & Housing Emissions

Although the presentations all follow the same format the details differ.  One of the more important components of the presentations is the emissions estimates and they all include a graphic showing historical emissions in 1990, “preliminary draft” emissions for 2018, and their projections for 2030 and 2050.  The 1990 emissions were defined in the Department of Environmental Conservation’s Part 496 regulations but the sectors used in that regulation are not comparable to this advisory panel’s sector.  In the following graph 1990 emissions are 103 million metric tons (MMt) of carbon dioxide equivalent[1] (CO₂e) and 2018 preliminary draft emissions are 115 MMt. 

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[1] The amount of carbon dioxide by mass that would produce the same global warming impact as the given mass of another greenhouse gas over a specific time frame, as determined by the IPCC, and as provided in Section 496.5 of this Part.

There are two emission reduction targets in the CLCPA: 40% reduction in GHG emissions by 2030 and 85% reduction in GHG Emissions by 2050.   The projected total reductions emission reduction goals for this advisory panel don’t meet either target only projecting a 27% reduction from 1990 by 2030 and a reduction of 83% by 2050. 

This sector was the largest source of greenhouse gas (GHG) emissions in 2018 but there are two caveats.  The New York emission inventory includes upstream GHG emissions and the emission rates for methane are high so over half the emissions relative to combustion come from imported fossil fuels.  In a rational world that observation would suggest an analysis to see why such an illogical outcome is observed but in the CLCPA it is a feature not a possible flaw.  The other factor is that refrigerants are a large component of the total because the global warming potential for HFC is high. 

Energy Efficiency & Housing Strategies

According to the meeting presentation, the advisory panel proposed the following four mitigating strategies and six enabling strategies:

• Mitigation strategy 1: Phase out fossil fuel use in buildings
• Mitigation strategy 2: Require benchmarking
• Mitigation strategy 3: Shift reliance on fossil gas to clean energy system
• Mitigation strategy 4: Shift reliance on HFC use as refrigerant and in all products used in construction
• Enabling strategy 1: Public financial incentives
• Enabling strategy 2: Public and private low-cost financing
• Enabling strategy 3: Workforce
• Enabling strategy 4: Consumer education
• Enabling strategy 5: Innovation
• Enabling strategy 6: Embodied carbon

The recommendations themselves are available in a slide presentation.  I am not going to critique all these strategies because it would take far too long.  Instead, I will comment on some of the strategies with an emphasis on inconsistencies and implementation issues. 

There is no question that meeting the CLCPA goals for this sector will be a challenge.  The presentation explains that there are 6.2 million buildings in New York State: 4.9m single family homes, 250k multifamily buildings, and 370k commercial/institutional buildings.  The first mitigation strategy is to phase out fossil fuel use in buildings.  Obviously “Eliminating GHG emissions from New York’s building stock by 2050 will require broad, systemic changes”.

The Energy Efficiency and Housing presentation to the Climate Action Council presentation summarizes the first initiative to modify building codes and standards in this strategy in the following slide.  The plan is to amend the state codes for new construction, including additions and alterations, to require solar PV on “feasible” areas, grid-interactive electrical appliances, energy storage readiness, electric readiness for all appliance and electric vehicle readiness.  They propose to adopt these all-electric state codes for single family residences by 2025 and for multifamily and commercial buildings by 2030. The presentation notes that by 2030, more than 200,000 homes per year will be upgraded to all-electric and energy efficient standards.

I suspect most people are like me and don’t understand what some of these terms mean and how it will affect my personal choices if I want to buy a new house or remodel my existing house in 2025. Solar panels will be required where “feasible” but feasibility is not defined.  Electric readiness means “The installation of electrical service and panel capacity, conduit, fixtures, and outlets for a future installation of electric equipment for space heating and cooling, hot-water, cooking, and laundry”.  This initiative proposes to prohibit (“at end of useful life”) gas or oil replacements of “heating, cooling and domestic hot water equipment” in single family homes by 2030 so it makes sense to install the electric infrastructure sooner.  Electric vehicle readiness is defined as the “installation of electrical service and panel capacity, conduit, fixtures, and outlets for a future installation of EV chargers”.  The transportation advisory panel has proposed that all new vehicles sold by 2030 will be electric vehicles so this is another consistent requirement. 

I was surprised that there was a requirement for energy storage readiness: “The installation of electrical service and panel capacity, conduit, fixtures, and outlets for a future installation of electric batteries”.  The biggest problem with solar energy is its intermittency and the advisory panel is proposing that homeowners help provide a solution by providing space for the batteries and footing the bill for the electrical service.  I suspect there will eventually be a requirement to install the batteries themselves but not to worry because the panel suggests that this will pay for itself by providing revenues.   The most intrusive aspect of this proposal is the requirement for grid-interactive electrical appliances “as feasible (e.g., batteries, hot water heaters)”.  For batteries the ability of the grid operator to call up your stored energy when needed makes sense but I am not comfortable having someone else decide when I can have hot water.  Moreover, heating and cooling appliances surely will eventually be grid-interactive too.  Proponents point out that capability would have helped reduce the impacts of the Texas February 2021 blackouts but cynics like me argue that the existing system does not need that capability because fossil fuels work better.

The presentation to the Climate Action Council notes that “Electrification of heating and hot water systems in nearly all buildings is a key strategy for building decarbonization and depends upon energy efficiency improvements in all buildings and 100% zero-emissions electricity by 2040 under the Climate Act”.  The second mitigation strategy sets benchmarking standards for building energy use.  New York State has a long history of support for energy efficiency.  I have long argued that the fatal flaw of the CLCPA is that it presumes that the targets are achievable despite the lack of a feasibility study to determine whether achieving the targets would adversely affect affordability and reliability.  In that context the question is where does the state stand vis-à-vis the energy efficiency needed for all-electric heating systems.  While converting to heat pumps is an overall energy use improvement, direct combustion on-site is more efficient actually warming homes because it provides hotter air.  The only way to be comfortable using heat pumps is to have an extremely well insulated building.

Also included in this initiative is another buried cost.  In particular, there are energy use disclosure requirements:

• Starting in 2025-Require owners of all residential and commercial buildings to obtain and publicly disclose, as part of sale or lease listing of a building, housing unit, or commercial space, the prior-year energy consumption of the building, unit, or space (e.g., at least 12 consecutive months of energy bill data).
• Starting in 2027–Require owners of single-family buildings to obtain and disclose an energy performance rating (e.g., a Home Energy Rating System (HERS) index) as part of sale listing.

The cost of these requirements will be borne by the owners.

The third mitigation strategy initiative is entitled “Gas System Transition”.  I believe it is included because the advisory panel knows that weaning the public off natural gas will be a challenge because of its advantages.  This difficulty is illustrated in the following slide listing the components required for delivery.  The first component states “Stop utilities advertising fossil gas as “clean,” “natural,” “climate friendly,” or in similar terms”.  The problem with not calling it natural gas of course is that it is called natural gas because it is a naturally occurring gas.  Wherever a geologic formation that contains natural gas is exposed to the air, natural gas can be released to the atmosphere.  For example, western New York’s Eternal Flame Falls has a vent that seeps natural gas, and someone, sometime lit it off.  Does this panel propose to change the signage there too?

The panel recommends six enabling strategies as shown in the enabling strategy summary slide below.  All but one are financial actions and two address only financial incentives and low-cost financing.  While the panel apparently realizes that cost is a major issue for this conversion, it is not clear whether they understand that general support for environmental issues evaporates when the personal impacts to costs and individual choices are explained.  This is illustrated by recent events in Great Britain where the implementation process for a similar net-zero target is further advanced than in New York.  When the government threatened to ban gas boilers in existing homes by 2035 and to fine homeowners if they met that deadline, the blowback was immediate.  Within hours the government backtracked and said there wouldn’t be any fines.  It will be interesting to see what happens now that the curtain has been pulled aside and the public starts to see all the costs to meet net-zero targets. 

Conclusion

The presentation slides suggest the difficulties facing this sector’s reduction targets:

• Eliminating GHG emissions from New York buildings by 2050 requires broad, systemic changes.
• Behavior and practice change lead to decarbonization
• Equitable transformation at this scale requires new resources.
• Private capital investment focused on highly efficient buildings
• Public incentives for early adoption
• Public investments in building efficiency and electrification in low and middle income homes, affordable and public housing, and disadvantaged communities
• Transformation at this scale and advancement of equity will require mobilizing private capital and a significant increase in public resources.
• The CAC should conduct an economy-wide analysis to identify resources and funding mechanisms to address the Scoping Plan, holistically.
• Advocate for Federal resources and policy support in the scoping plan.
• Continue PSC attention to rate design and retail rates for electricity and gas.
• Resilience is of critical importance. Amend State codes to enhance building-level resilience and grid reliability/resilience.
• Support recommendations of the Adaptation and Resilience group.
• Broad adoption of insulation/weatherization and energy efficiency in homes; increased funding for weatherization and energy efficiency in LMI homes; energy disclosures can inform future policy.

These are all aspirational gambits that on one hand are necessary but on the other hand are no means assured.  The comment stating resilience is of critical importance is a hollow gesture.  Fossil fuels provide more resilience in general and in the event of extreme weather such as an ice storm reliance on electric heat and renewable energy will have fatal consequences.  Importantly, the public gets that and I doubt will not willingly give up the capabilities of natural gas and fuel oil for heating.

One notable aspect of these recommendations is the inclusion of specific components that favor the interests of individual members of the advisory panel.  This is a common problem for all the advisory panels caused by the membership selection process.  For example, the gas system transition includes the following component: “Level the playing field for adoption of clean heating solutions by eliminating the “100-foot rule” which can bias customer decision-making around heating choices. (The 100-foot rule covers most or all of the cost of new gas connections for residential customers and significant costs for new non-residential firm gas customers).”  Given that all the clean heating solutions are directly subsidized and that when everything is electrified the distribution systems will likely have to be upgraded which represents an indirect subsidy, the “level the playing field” argument can only come from a vested interest blinded to the contradictions.

These panel recommendations and the facts that this sector has the highest emissions and the does not meet the projected targets is a problem for the CLCPA.  When I describe the limits on personal choices for energy use and added costs most people don’t accept that this could be possible.  I believe that public backlash will be similar to what has been observed in Great Britain when the implications and costs become readily known.  If the public response forces reconsideration of the enabling initiatives, then it will weaken the potential emission reduction strategies making achievement of the CLCPA targets that much more difficult.